United States Environmental Protection Agency Municipal Environmental Research Laboratory Cincinnati OH 45268 Research and Development EPA-600/S2-81-239 Jan. 1982 Project Summary Guide for Spill Prevention Control and Countermeasure Inspectors Walter Unterberg and Robert M. Moorehead This report is intended for use in training and guiding inspectors performing compliance inspections and amendment inspections and in documenting these inspections to implement the Oil Pollution Preven- tion Regulations promulgated in 40CFR112 for nontransportation- related onshore and offshore facilities. The report covers the Spill Prevention Control and Counter- measure (SPCC) regulations, the role of the SPCC inspector, the affected facilities, and procedures for carrying out the inspection. It contains forms for use by the inspector in the field and for documentation. The use of these forms will provide nationwide uniformity in SPCC reporting. Suggested procedures appear below in short form, applicable to all inspections: The SPCC Inspector's 1-2-3 1. In field, fill out "SPCC Inspection Field Sheet" (1 page) (EPA Form 7500-53) 2. If facility in compliance Fill out "APCC Inspection Sum- mary Sheet" (1 page) only (EPA For 7500-52) // facility NOT in compliance Fill out "SPCC Inspection Summary Sheet" (1 page) (EPA Form 7500-52) and "Detailed SPCC Documentation" (7 pages) (EPA Form 7500-54) ,3. Enter information in EPA-SPCC Data Bank; Form A - Facility Indentification Form E - Inspection/Enforce- ment Report Form S - Spill Report (if required) This Project Summary was devel- oped by EPA 's Municipal Environmen- tal Research Laboratory, Cincinnati. OH, to announce key findings of the research project that is fully docu- mented in a separate report of the same title (see Project Report order- ing information at back). Introduction In December 1973, the U.S. Environmental Protection Agency (EPA) issued in the Federal Register its Oil Pollution Prevention Regulations for Nontransportation-Related Onshore and Offshore Facilities (40CFR112). The purpose of these regulations is to prevent spills from nontransportation- related facilities by establishing procedures, methods, and equipment requirements for owners or operators of facilities engaged in drilling, producing, gathering, storing, processing, refining, transferring, distributing, or consuming oil. These regulations require the owners or operators of designated onshore and offshore facilities to ------- prepare a Spill Prevention Control and Countermeasure Plan (SPCC Plan) in accordance with certain guidelines contained within the regulations. These guidelines require the installation or construction of certain spill prevention systems depending upon the type of operation conducted at the facility. The intention of these regulations is that these spill prevention systems be designed, installed, and operated according to good engineering practices. Associated with 40CFR112 are sev- eral other environmental regulations: • 40CFR109, Criteria for State, Local, and Regional Oil Removal Contingency Plans — governing contingency plans that are part of SPCC plans under certain circum- stances when conventional spill prevention is not feasible; • 40CFR110, Discharge of Oil — applying 'to the discharge of oil into navigable waters, adjoining shorelilnes, or waters of the con- tiguous zone; • 40CFR114, Civil Penalties for Vio- lation of Oil Pollution/Prevention Regulations — outlining enforce- ment procedures, with maximum liability of $5000 for each day a violation continues. The SPCC inspection program is the mechanism that the EPA uses to determine compliance with SPCC regulations. Compliance inspections enforce 40CFR112.3 by verifying that an SPCC plan exists for a facility falling under 40CFR112, that this plan is technically adequate, and that the provisions of the SPCC plan have actually been carried out in the facility. The legal basis for compliance inspections is contained in 40CFR112.3(b), which states, in part: "Owners or operators of a facility for which an SPCC plan is required ... shall maintain a complete copy of the plan . . . and shall make such plan available to the Regional Administrator for on-site review during normal working hours." When a spill of a certain magnitude has occurred from a facility having an SPCC plan, 40CFR112.4 requires the owner or operator to submit his SPCC plan to the EPA Regional Administrator for review and possible amendment. The Regional Administrator may require that the plan be amended to minimize the possibilities of spill recurrence. After EPA review of the plan, an amendment inspection may be performed; this may result in additional SPCC requirements being specified by the EPA. The legal basis for this is contained in 40CFR112.4(d), which states, in part: "After review of the SPCC plan ... submitted by the owner or operator . . . the Regional Administrator may require the owner or operator.. .to amend the SPCC Plan if he finds that the Plan does not meet the requirements of this part or that the amendment of the plan is necessary to prevent and to contain discharges of oil from such a facility . . . and shall specify the terms of such amendment." EPA's SPCC regulations were to be implemented by 11 January 1975 by about 30,000 oil marketing terminals and bulk plants; about 285 oil refineries; several thousand production facilities, both onshore and offshore; and many bulk oil consumers. As of June 1976, the EPA had completed 12,313 compliance inspections. Evaluation of the SPCC program to date, in terms of spill histories and enforcement, has disclosed variations among the EPA regions. Objective Uniformity in carrying out SPCC inspections is desirable, and therefore, a document that provides uniform guidance on a nationwide basis is required. Also, personnel new to the SPCC program need to be trained in inspection and documentation procedures. This "Guide for Spill Prevention Control Countermeasure Inspectors" is to be a training and guidance report for those performing compliance inspections and amendment inspections and for documenting such inspections to enforce the Oil Pollution Prevention Regulations promulgated in 40CFR112 for nontransportation- related onshore and offshore facilities. Operators/owners of such facilities should also find this report useful in developing their SPCC plans. Contents This report is divided into sections. Section 1 is the introduction. Section 2 describes the role of the SPCC inspec- tor, including the knowledge and skills he should possess, the attitude and behavior he should exhibit when deal- ing with facility personnel, and the attire and equipment he should take into the field. Section 3 briefly covers the af- fected nontransportation-related facili- ties and their potential for incurring oil spills. Section 4 is devoted to compliance inspections — starting with prepara- tions for the inspection, then cpntinuing with the initial contact with the facility and the SPCC plan review, and ending with the facility inspection itself. Sec- tion 5 deals with amendment inspec- tions and parallels 4 in its sections. Sec- tion 6 deals with documentation of inspections. This is followed by a sec- tion on references. The appendices include texts of the applicable federal EPA SPCC regula- tions (Appendix A), a discussion of nontransportation-related facilities (Appendix B), an SPCC inspection check- . list (Appendix C), Report of SPCC In- \ spection forms (Appendix D), and EPA- SPCC Data Bank forms (Appendix E). The report concludes with a Glossary of the most commonly used terms. The report is in looseleaf form so that future additions, deletions, and correc- tions can easily be made. Also, it per- mits the report holder to insert other pages as desired. The full report was submitted in par- tial fulfillment of Contract No. 68-03- 2648 by Rockwell International, New- buryPark, California, under the sponsor- ship of the U.S. Environmental Protection Agency. ------- W. Unterberg and R. M. Moorehead are with Rockwell International, Environ- mental Monitoring & Services Center, Newbury Park, CA 91320. John S. Farlow is the EPA Project Officer (see below). The complete report, entitled "Guide for Spill Prevention Control and Counter- measure Inspectors," (Order No. PB 82-115 296; Cost: $12.00, subject to change) will be available only from: National Technical Information Service 5285 Port Royal Road Springfield, VA 22161 Telephone: 703-487-4650 The EPA Project Officer can be contacted at: Oil and Hazardous Materials Spills Branch Municipal Environmental Research Laboratory—Cincinnati U.S. Environmental Protection Agency Edison, NJ 08837 U S GOVERNMENT PRINTING OFFICE, 1982 —559-017/7437 ------- United States Environmental Protection Agency Center for Environmental Research Information Cincinnati OH 45268 Postage and Fees Paid Environmental Protection Agency EPA 335 Official Business Penalty for Private Use $300 RETURN POSTAGE GUARANTEED PS 0000329 ------- |